Policy GNLP5022

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Object

Greater Norwich Local Plan Gypsy and Traveller Sites Focused Consultation

Representation ID: 24774

Received: 06/03/2023

Respondent: Hawk and Owl Trust

Representation Summary:

Our land adjacent to the proposed site, is part of a local community woodland initiative.

Since the land has been gifted to the Trust we have suffered over £5000 of damage to this land, including cut fence posts and illegal dumping of waste on the land.

Therefore we object to any further expansion.

Full text:

Our land adjacent to the proposed site, is part of a local community woodland initiative.

Since the land has been gifted to the Trust we have suffered over £5000 of damage to this land, including cut fence posts and illegal dumping of waste on the land.

Therefore we object to any further expansion.

Object

Greater Norwich Local Plan Gypsy and Traveller Sites Focused Consultation

Representation ID: 24970

Received: 07/03/2023

Respondent: Themelthorpe Parish Group

Representation Summary:

Reference: GNLP5022 The Oaks Foulsham
Comments have been submitted by the residents of Themelthorpe village to the Chairperson and the document below is a summary of these.


‘The residents of Themelthorpe wish to express their objection to the potential increase of pitches at The Oaks traveller site on Reepham Road, Foulsham as outlined in the recently published Greater Norwich Local Plan’

Introduction:
The Oaks is situated on the outskirts of the Parish of Foulsham and on the boundary of the village of Themelthorpe.
To increase the number of pitches on the site and thus the number of people accommodated therein, would make the scale of The Oaks and its impact on the local environment too large for such a small village with no amenities and out of keeping with this quiet, rural area.
An expansion of the site would have a detrimental impact on the local landscape.

Background Information:
The original planning permission granted, after appeal, for The Oaks was on the basis that the site was to house two families, comprising two log cabin style static caravans, a shared amenity block, parking for four vehicles and storage for two additional touring (not static) caravans.
The planning application also stated that the number of vehicle movements in and out of the site would not exceed six per day and that there would be no changes to vehicle or pedestrian access to or from the public highway.

Existing Occupancy:
It is clear to see from the road, and the google map image attached (Ref Image 1), that the number of buildings now on the site is greatly in excess of the number allowed under the granted planning permission.
This is also evident from the number of wheelie bins put out for collection each week. (Ref: Image 2)

There are now more families, with more vehicles, living on site than was granted in the original application. The number of daily vehicle movements in and out of the site is way in excess of the six stated in the planning application with vehicle movements throughout the day often late at night and in the early hours of the morning.

An unauthorised access road, from Reepham Road, has been added by bulldozing a gap through oak trees on the North side of the site. A very high fence, has also been erected either side of the track.

No evidence of planning application for these works can be found.
We understand from the Enforcement Officer, that he has an open case for the site. He confirmed that he has not visited the site since last summer but is intending to do so in the near future to assess the current situation.

We understand that at least 2 large static caravans/portacabin style buildings were delivered to the site last month.

Highways:
We have major concerns regarding transport suitability and accessibility into the site.
The road network serving this site is made up of small narrow lanes.
Any additional resident cars, towing vans and HGVs would cause severe detriment to these highways already pitted with potholes and uneven surfaces.

There is an ongoing problem with vehicles speeding into Themelthorpe from Foulsham.
Two cases of vehicles coming off the road and into residential properties have been reported to Highways this winter alone.
Themelthorpe has no street lighting and no pedestrian footpaths, increased vehicles and possible speeding issues would add to an already proven safety hazard to Themelthorpe residents and the wider public.

Referring to recent and relevant planning permission for land adjoining The Oaks (Source Planning Application 20210651 Mayfields Farm),
the Highways Development Management Officer states “Given the nature of the rural road network that serves this site, I have highway safety concerns about the acceptability of this proposal which involves both towing and large vehicles” …… “thus raising transport suitability or accessibility concerns at what is a remote and fairly isolated location”.
These statements made by NCC professionals must therefore also apply to The Oaks, being located next to Mayfields Farm.

Pollution:
We have major pollution concerns regarding the existing provisions for sewage on the site given the unauthorised current increase in occupants.

The site is located on heavy land with a high water table and any further development comes with a risk of increased flooding in an area already experiencing significant flooding and drainage problems.

We understand that any development on the site would also be required to meet the new ‘Nutrient Neutrality Regulations’ currently being implemented by NCC and Natural England.
What provision is being made for this in your plan?
Will the landowner be required to obtain a survey to assess their impact, as required by any other developers/individuals?


Environmental & Safety Concerns:
Due to the location of a gas pipe that runs across the site, you indicate in your ‘Selected Site report’ that ‘any development would need to be in the northern part of the site’.

Any building positioned on the northern side would be visible from the road, causing a detrimental impact on the rural landscape.
Although mitigation for landscape disruption would presumably be included in the permission, what guarantee would there be that this would be adhered to, given the track record of the landowner and the difficulties of any enforcement?

The risk of a potential hazard should any building works crossing or interfering with the gas pipe is extremely severe. Any development would have to be monitored and strictly adhered to with all safety rules/risk assessments clearly communicated to all interested parties.

Concern has been raised that a building has already taken place in the area of the gas pipeline.


Noise Pollution & Antisocial behaviour:
Some local residents have experienced excessive disturbances at unsocial hours, as well as aggressive and anti social behaviour from the existing occupants at The Oaks, as well as a disregard for the local environment.


Adverse impacts on Biodiversity and The Landscape:
The land on either side of the proposed site is owned by conservation charities. Mayfields Farm is a 40 acre grassland farm owned by the Countryside Regeneration Trust and managed for the benefit of wildlife and education.

The land on the other side is owned by the Hawk and Owl Trust and has been earmarked for the creation of a community woodland with the longer term objective of creating a nature reserve as part of a wildlife corridor along the old railway line.
We cannot find any evidence that the Local Authorities have taken the potential damage to these conservation projects into consideration.
The additional vehicular access mentioned previously, has already caused irreversible damage to the local flora and fauna.


Summary:
It would appear that the site already provides an increased number of pitches albeit without permission!
Are you proposing to retrospectively grant permission for the additional pitches erected without permission?
Would your proposed new allocation of 5 pitches be in addition to or including these, thereby making the total number of dwellings on the site closer to 10?

The continued breach of planning procedures and rules is of great concern in the context of any potential extension of the site. It is a reasonable assumption that further breaches would occur, without consequence, meaning the true impact of the expanded site would be far greater than the proposal permits.

The precedent of Highways response to ‘Mayfields’ recent planning application (referenced above) must be wholly applicable on the case of The Oaks expansion.

This concern is magnified by the evidence that Broadland Council have been unable to ensure that the original granted permission has not been exceeded and thus protect the interests and wellbeing of those living nearby.

Whilst acknowledging the need for travellers to be provided with sites on which to live this cannot be at the expense of the localities and environments in which they settle.
It is our collective view that The Oaks at its current scale already provides a fair contribution to the needs required.

Full text:

Reference: GNLP5022 The Oaks Foulsham
Comments have been submitted by the residents of Themelthorpe village to the Chairperson and the document below is a summary of these.


‘The residents of Themelthorpe wish to express their objection to the potential increase of pitches at The Oaks traveller site on Reepham Road, Foulsham as outlined in the recently published Greater Norwich Local Plan’

Introduction:
The Oaks is situated on the outskirts of the Parish of Foulsham and on the boundary of the village of Themelthorpe.
To increase the number of pitches on the site and thus the number of people accommodated therein, would make the scale of The Oaks and its impact on the local environment too large for such a small village with no amenities and out of keeping with this quiet, rural area.
An expansion of the site would have a detrimental impact on the local landscape.

Background Information:
The original planning permission granted, after appeal, for The Oaks was on the basis that the site was to house two families, comprising two log cabin style static caravans, a shared amenity block, parking for four vehicles and storage for two additional touring (not static) caravans.
The planning application also stated that the number of vehicle movements in and out of the site would not exceed six per day and that there would be no changes to vehicle or pedestrian access to or from the public highway.

Existing Occupancy:
It is clear to see from the road, and the google map image attached (Ref Image 1), that the number of buildings now on the site is greatly in excess of the number allowed under the granted planning permission.
This is also evident from the number of wheelie bins put out for collection each week. (Ref: Image 2)

There are now more families, with more vehicles, living on site than was granted in the original application. The number of daily vehicle movements in and out of the site is way in excess of the six stated in the planning application with vehicle movements throughout the day often late at night and in the early hours of the morning.

An unauthorised access road, from Reepham Road, has been added by bulldozing a gap through oak trees on the North side of the site. A very high fence, has also been erected either side of the track.

No evidence of planning application for these works can be found.
We understand from the Enforcement Officer, that he has an open case for the site. He confirmed that he has not visited the site since last summer but is intending to do so in the near future to assess the current situation.

We understand that at least 2 large static caravans/portacabin style buildings were delivered to the site last month.

Highways:
We have major concerns regarding transport suitability and accessibility into the site.
The road network serving this site is made up of small narrow lanes.
Any additional resident cars, towing vans and HGVs would cause severe detriment to these highways already pitted with potholes and uneven surfaces.

There is an ongoing problem with vehicles speeding into Themelthorpe from Foulsham.
Two cases of vehicles coming off the road and into residential properties have been reported to Highways this winter alone.
Themelthorpe has no street lighting and no pedestrian footpaths, increased vehicles and possible speeding issues would add to an already proven safety hazard to Themelthorpe residents and the wider public.

Referring to recent and relevant planning permission for land adjoining The Oaks (Source Planning Application 20210651 Mayfields Farm),
the Highways Development Management Officer states “Given the nature of the rural road network that serves this site, I have highway safety concerns about the acceptability of this proposal which involves both towing and large vehicles” …… “thus raising transport suitability or accessibility concerns at what is a remote and fairly isolated location”.
These statements made by NCC professionals must therefore also apply to The Oaks, being located next to Mayfields Farm.

Pollution:
We have major pollution concerns regarding the existing provisions for sewage on the site given the unauthorised current increase in occupants.

The site is located on heavy land with a high water table and any further development comes with a risk of increased flooding in an area already experiencing significant flooding and drainage problems.

We understand that any development on the site would also be required to meet the new ‘Nutrient Neutrality Regulations’ currently being implemented by NCC and Natural England.
What provision is being made for this in your plan?
Will the landowner be required to obtain a survey to assess their impact, as required by any other developers/individuals?


Environmental & Safety Concerns:
Due to the location of a gas pipe that runs across the site, you indicate in your ‘Selected Site report’ that ‘any development would need to be in the northern part of the site’.

Any building positioned on the northern side would be visible from the road, causing a detrimental impact on the rural landscape.
Although mitigation for landscape disruption would presumably be included in the permission, what guarantee would there be that this would be adhered to, given the track record of the landowner and the difficulties of any enforcement?

The risk of a potential hazard should any building works crossing or interfering with the gas pipe is extremely severe. Any development would have to be monitored and strictly adhered to with all safety rules/risk assessments clearly communicated to all interested parties.

Concern has been raised that a building has already taken place in the area of the gas pipeline.


Noise Pollution & Antisocial behaviour:
Some local residents have experienced excessive disturbances at unsocial hours, as well as aggressive and anti social behaviour from the existing occupants at The Oaks, as well as a disregard for the local environment.


Adverse impacts on Biodiversity and The Landscape:
The land on either side of the proposed site is owned by conservation charities. Mayfields Farm is a 40 acre grassland farm owned by the Countryside Regeneration Trust and managed for the benefit of wildlife and education.

The land on the other side is owned by the Hawk and Owl Trust and has been earmarked for the creation of a community woodland with the longer term objective of creating a nature reserve as part of a wildlife corridor along the old railway line.
We cannot find any evidence that the Local Authorities have taken the potential damage to these conservation projects into consideration.
The additional vehicular access mentioned previously, has already caused irreversible damage to the local flora and fauna.


Summary:
It would appear that the site already provides an increased number of pitches albeit without permission!
Are you proposing to retrospectively grant permission for the additional pitches erected without permission?
Would your proposed new allocation of 5 pitches be in addition to or including these, thereby making the total number of dwellings on the site closer to 10?

The continued breach of planning procedures and rules is of great concern in the context of any potential extension of the site. It is a reasonable assumption that further breaches would occur, without consequence, meaning the true impact of the expanded site would be far greater than the proposal permits.

The precedent of Highways response to ‘Mayfields’ recent planning application (referenced above) must be wholly applicable on the case of The Oaks expansion.

This concern is magnified by the evidence that Broadland Council have been unable to ensure that the original granted permission has not been exceeded and thus protect the interests and wellbeing of those living nearby.

Whilst acknowledging the need for travellers to be provided with sites on which to live this cannot be at the expense of the localities and environments in which they settle.
It is our collective view that The Oaks at its current scale already provides a fair contribution to the needs required.

Attachments:

Comment

Greater Norwich Local Plan Gypsy and Traveller Sites Focused Consultation

Representation ID: 24995

Received: 09/03/2023

Respondent: Anglian Water Services Ltd

Representation Summary:

POLICY GNLP5022 LAND OFF REEPHAM ROAD, THE OAKS, FOULSHAM
3.12. The site is located within reasonable proximity to connect to our water supply network, but due to its rural location, it is not within reasonable distance of our water recycling network catchments.

Full text:

1. Anglian Water
1.1. Anglian Water is the water and water recycling provider for over 6 million customers in the east of England. Our operational area spans between the Humber and Thames estuaries and includes around a fifth of the English coastline. The region is the driest in the UK and the lowest lying, with a quarter of our area below sea level. This makes it particularly vulnerable to the impacts of climate change including heightened risks of both drought and flooding, including inundation by the sea.
1.2. Anglian Water has amended its Articles of Association to legally enshrine public interest within the constitutional make up of our business – this is our pledge to deliver wider benefits to society, above and beyond the provision of clean, fresh drinking water and effective treatment of used water. Our Purpose is to bring environmental and social prosperity to the region we serve through our commitment to Love Every Drop.
2. Anglian Water and Local Plans 2.1. Anglian Water is is the statutory water and sewerage undertaker for the Greater Norwich Local Plan (GNLP) area and a statutory consultee under The Town and Country Planning (Local Planning) (England) Regulations 2012. Anglian Water wants to proactively engage with the local plan process to ensure the plan delivers benefits for residents and visitors to the area, and in doing so protect the environment and water resources. As a purpose-led company, we are committed to seeking positive environmental and social outcomes for our region.
3. Commentary on the GNLP Gypsy & Traveller Sites Focused Consultation
3.1. Anglian Water has contributed to the utilities assessment of the proposed Gypsy and Traveller sites regarding connections to our water supply and water recycling networks and any identified encroachment issues on our assets/network.
3.2. We recognise the wider policy considerations that inform the selection of proposed sites within this consultation. The ability to connect to our networks where sites are adjacent to larger settlements that are serviced by a water recycling centre (WRC) means there are more sustainable and resilient options to treating wastewater arising from Gypsy and Traveller sites. Many of the sites are in rural locations or not closely related to our WRC catchments and therefore are likely to be reliant on non-mains sewerage solutions such as private package treatment plans. A joint advice note by Anglian Water and the Environment Agency in relation to non-mains sewerage options can be found on our website1.
1 https://www.anglianwater.co.uk/contentassets/ff314e5a2ec1452387d7aa04f6519c33/2020-11-10-aw-ea-non-mains-sewerage-advice-note---final.pdf
09.03.2023
2
POLICY GNLP5004 LAND OFF BUXTON ROAD, EASTGATE, CAWSTON
3.3. Anglian Water notes the site is located close to existing development within the settlement, and therefore it is within a reasonable distance to connect to our water supply and water recycling networks.
POLICY GNLP5005 LAND AT STRAYGROUND LANE WYMONDHAM RECYCLING CENTRE, WYMONDHAM
3.4. As referenced as part of the initial assessment, this site is within reasonable proximity to connect to our water supply network, but it is located outside the Wymondham water recycling catchment.
POLICY GNLP5009 LAND OFF HOCKERING LANE, BAWBURGH
3.5. Anglian Water notes the site is located close to existing development within the settlement, and within a reasonable distance to connect to our water supply and water recycling networks.
POLICY GNLP5014 A47 NORTH BURLINGHAM JUNCTION
3.6. The site is located within reasonable proximity to connect to our water supply network, but due to its rural location, it is not within reasonable distance of our water recycling network catchments.
3.7. The A47 road improvement scheme will require the diversion of our assets at this location, and this should be a consideration for future connections.
POLICY GNLP5019 WOODLAND STABLE, SHORTTHORN ROAD, STRATTON STRAWLESS
3.8. The site is located within reasonable proximity to connect to our water supply network, and is adjacent to the Aylsham water recycling catchment, although this part of the network operates as a vacuum sewer system which can take up to 24 months for a connection due to the requirements to assess the capacity of the network. We would suggest that any policy should include a requirement for early engagement with Anglian Water regarding connection to our water recycling network.
POLICY GNLP5020 ROMANY MEADOW, THE TURNPIKE, CARLETON RODE
3.9. The site is located within reasonable proximity to connect to our water supply network, but due to its rural location, it is not within reasonable distance of our water recycling network catchments.
POLICY GNLP5021 LAND OFF HOLT ROAD, HORSFORD
3.10. The site is located within reasonable proximity to connect to our water supply network, but due to its rural location, it is not within reasonable distance of our water recycling network catchments.
3.11. There is a mains water pipe to the northern boundary of the site. We will require sufficient stand-off distances around the water main or diversion at the developers' cost and to the satisfaction of Anglian Water. Further information on the location of our assets can be obtained via utilities.digdat.co.uk
09.03.2023
3
POLICY GNLP5022 LAND OFF REEPHAM ROAD, THE OAKS, FOULSHAM
3.12. The site is located within reasonable proximity to connect to our water supply network, but due to its rural location, it is not within reasonable distance of our water recycling network catchments.
POLICY GNLP5023 LAND OFF STRAYGROUND LANE, WYMONDHAM
3.13. The site is located within reasonable proximity to connect to our water supply network, but due to its rural location, it is not within reasonable distance of our water recycling network catchments.
POLICY GNLP5024 UPGATE STREET, CARLETON RODE
3.14. This site does not appear to be in close proximity to a water supply connection or our water recycling network. As the neighbouring site is occupied and was granted planning permission in 2010, there is an assumption that a water supply is available and sewerage treatment is confirmed as a package treatment plant through the documents submitted with the planning application.
Reasonable Alternative
POLICY GNLP5013 KETTERINGHAM DEPOT LAND WEST OF STATION LANE, KETTERINGHAM
3.15. As a reasonable alternative site, Anglian Water notes that the site is located within reasonable proximity to connect to our water supply network, but it is not within reasonable distance of our water recycling network catchments.
Unreasonable Alternatives
VCHAP SITE 1 AND SITE 2, MIDDLE ROAD, DENTON
3.16. Anglian Water notes the constraints identified regarding these sites and reasons why they have not been brought forward. In terms of access to our water supply and water recycling networks we can state that these sites are located within reasonable proximity to connect to our water supply network, but due to the rural location of these sites, they are not within reasonable distance to connect to our water recycling network catchments.
4. Conclusion
4.1. Anglian Water has assessed the potential to access our water supply and water recycling networks for the proposed Gypsy and Traveller Sites and identified where there are policy requirements regarding connections to our network or to ensure sufficient measures are in place to protect our assets within or adjacent to the proposed sites.

Object

Greater Norwich Local Plan Gypsy and Traveller Sites Focused Consultation

Representation ID: 25022

Received: 10/03/2023

Respondent: Foulsham Parish Council

Representation Summary:

Foulsham Parish Council overwhelmingly objects to further development of the Oaks site. The reasons given by the councillors are summarised as follows:
There are already three traveller sites in the vicinity which is disproportionate for a small village.
The Oaks is a large plot, which could potentially accommodate many more pitches. Allowing another 5 pitches simply paves the way for them, and for other sites to increase their pitches.
The authorities ignored our objection when the Oaks was proposed and it is understood that the council allowed them to stay, but for only a fixed period of time.
The site is not suitable for further occupation. There have been concerns raised before about waste disposal and it is understood that permission was never sought nor granted for the access onto Reepham Road.
It is believed that there has already been unauthorised expansion of the site.
Additional comments received from residents:
Resident 1
It is understood that previous, unauthorised expansion of the site, including the addition of a second driveway onto Reepham Road has gone unchallenged by the council and the site is already in significant contravention of the previously granted planning permission. Therefore we do not feel that any further development of the site should even be considered until all outstanding contraventions are addressed and resolved. The site is also far outside of the settlement boundary and nowhere near any amenities.
Resident 2
We wish to lodge our objection in the strongest possible terms to the potential increase of The Oaks traveller site on Reepham Road , Foulsham by an additional five pitches as outlined in the recently published Greater Norwich Local Plan. To increase the number of pitches on the site in this way, and thus the number of people accommodated on the site, would make the scale of The Oaks and its impact on the local environment too large for such a small village with limited amenities and out of keeping with this quiet, rural area. Such an expansion of the site would have a detrimental impact on the local landscape and the ability of local residents to enjoy the peace and tranquility of this area which is the prime reason for many of them choosing to live in this location.
When planning permission was granted for The Oaks, on appeal after originally being turned down, it was on the basis that the site was to be home for two siblings and their families, each sibling having two young children and thus there would be eight people resident on the site. The site was to consist of two log cabin style static caravans, a shared amenity block providing kitchen and bathroom facilities, parking for four vehicles and storage for two touring caravans. The planning application also stated that the number of vehicle movements in and out of the site would not exceed six per day and that there would be no changes to vehicle or pedestrian access to or from the public highway.
It is clear to see from the road that the number of buildings now on the site is greatly in excess of the number allowed under the granted planning permission and there are now also more people living on the site, along with more vehicles, than was stated in the application. The number of daily vehicle movements in and out of the site is way in excess of the six stated in the planning application with vehicle movements late at night and in the early hours of the morning. A new access to the site from Reepham Road has also been added by bulldozing a gap through the oak trees on the North side of the site causing damage to those trees. A very high and ugly fence has also been erected either side of the track through which the new access goes.
All of the additional buildings, the new access and the large fence that have been erected have been added without seeking any additional planning approvals. The residents of The Oaks clearly see themselves as being above the law and this flagrant breach of planning rules is of great concern in the context of the potential extension of the site. It is highly likely that any new residents of The Oaks would be of a similar mindset and thus the final size and true impact of the expanded site would in reality be far greater than any permissions granted. This is deeply worrying when it also appears that Broadland Council are not prepared to ensure that granted permissions are not exceeded and thus protect the interests and wellbeing of those living near to The Oaks.
The residents of The Oaks have regularly been the source of excessive noise, including the racing of quad bikes on other people’s land in and around Themelthorpe village, which has been detrimental to the enjoyment of the area for other nearby villagers and they have continually shown that they do not respect the local environment in any way. Local residents have also been subjected to threats and intimidation from the residents of The Oaks. These negative impacts will only increase if the site is allowed to grow further.
Whilst acknowledging the need for travellers to be provided with sites on which to live this cannot be at the expense of the localities and environments in which they settle. Developments allowed in any area, whether related to the traveller or non-traveller communities, should be in keeping with the character of the areas and should not have an adverse effect on the local environment. It is our view that with The Oaks at its current scale and with the Oaklands site also on Reepham Road that Foulsham/Themelthorpe has already provided its fair share of traveller sites for such a small village and that other areas of the county must now be found to accommodate additional needs.

Full text:

Foulsham Parish Council overwhelmingly objects to further development of the Oaks site. The reasons given by the councillors are summarised as follows:

There are already three traveller sites in the vicinity which is disproportionate for a small village.

The Oaks is a large plot, which could potentially accommodate many more pitches. Allowing another 5 pitches simply paves the way for them, and for other sites to increase their pitches.

The authorities ignored our objection when the Oaks was proposed and it is understood that the council allowed them to stay, but for only a fixed period of time.

The site is not suitable for further occupation. There have been concerns raised before about waste disposal and it is understood that permission was never sought nor granted for the access onto Reepham Road.

It is believed that there has already been unauthorised expansion of the site.


Additional comments received from residents:

Resident 1
It is understood that previous, unauthorised expansion of the site, including the addition of a second driveway onto Reepham Road has gone unchallenged by the council and the site is already in significant contravention of the previously granted planning permission. Therefore we do not feel that any further development of the site should even be considered until all outstanding contraventions are addressed and resolved. The site is also far outside of the settlement boundary and nowhere near any amenities.

Resident 2
We wish to lodge our objection in the strongest possible terms to the potential increase of The Oaks traveller site on Reepham Road , Foulsham by an additional five pitches as outlined in the recently published Greater Norwich Local Plan. To increase the number of pitches on the site in this way, and thus the number of people accommodated on the site, would make the scale of The Oaks and its impact on the local environment too large for such a small village with limited amenities and out of keeping with this quiet, rural area. Such an expansion of the site would have a detrimental impact on the local landscape and the ability of local residents to enjoy the peace and tranquility of this area which is the prime reason for many of them choosing to live in this location.

When planning permission was granted for The Oaks, on appeal after originally being turned down, it was on the basis that the site was to be home for two siblings and their families, each sibling having two young children and thus there would be eight people resident on the site. The site was to consist of two log cabin style static caravans, a shared amenity block providing kitchen and bathroom facilities, parking for four vehicles and storage for two touring caravans. The planning application also stated that the number of vehicle movements in and out of the site would not exceed six per day and that there would be no changes to vehicle or pedestrian access to or from the public highway.

It is clear to see from the road that the number of buildings now on the site is greatly in excess of the number allowed under the granted planning permission and there are now also more people living on the site, along with more vehicles, than was stated in the application. The number of daily vehicle movements in and out of the site is way in excess of the six stated in the planning application with vehicle movements late at night and in the early hours of the morning. A new access to the site from Reepham Road has also been added by bulldozing a gap through the oak trees on the North side of the site causing damage to those trees. A very high and ugly fence has also been erected either side of the track through which the new access goes.

All of the additional buildings, the new access and the large fence that have been erected have been added without seeking any additional planning approvals. The residents of The Oaks clearly see themselves as being above the law and this flagrant breach of planning rules is of great concern in the context of the potential extension of the site. It is highly likely that any new residents of The Oaks would be of a similar mindset and thus the final size and true impact of the expanded site would in reality be far greater than any permissions granted. This is deeply worrying when it also appears that Broadland Council are not prepared to ensure that granted permissions are not exceeded and thus protect the interests and wellbeing of those living near to The Oaks.

The residents of The Oaks have regularly been the source of excessive noise, including the racing of quad bikes on other people’s land in and around Themelthorpe village, which has been detrimental to the enjoyment of the area for other nearby villagers and they have continually shown that they do not respect the local environment in any way. Local residents have also been subjected to threats and intimidation from the residents of The Oaks. These negative impacts will only increase if the site is allowed to grow further.

Whilst acknowledging the need for travellers to be provided with sites on which to live this cannot be at the expense of the localities and environments in which they settle. Developments allowed in any area, whether related to the traveller or non-traveller communities, should be in keeping with the character of the areas and should not have an adverse effect on the local environment. It is our view that with The Oaks at its current scale and with the Oaklands site also on Reepham Road that Foulsham/Themelthorpe has already provided its fair share of traveller sites for such a small village and that other areas of the county must now be found to accommodate additional needs.

Comment

Greater Norwich Local Plan Gypsy and Traveller Sites Focused Consultation

Representation ID: 25064

Received: 13/03/2023

Respondent: Historic England

Representation Summary:

This is an extension of an existing site. Whilst there are no designated heritage assets within the site, the grade II* church of St Andrew lies to the south east of the site. There are three grade II listed buildings close by including Manor Farm House to the west, Old Hall to the East and Old Hall Farmhouse to the north east of the site. However, the site is well screened and there is intervening off- site vegetation. Therefore, we consider any impact on designated heritage assets would be minimal.
We welcome bullet point 4 in relation to landscaping to protect views of nearby listed buildings.

Full text:

SUMMARY
Whilst we consider many aspects of the plan to be sound, we have identified issues
with some of the policies and site allocations which do compromise the overall
soundness of the plan.
Under paragraph 35 of the NPPF some aspects of this Plan are unsound as they
have not been positively prepared, are not justified, effective, or consistent with
national policy. We have identified below some of the key areas where we find the
Plan unsound and what measures are needed to make the Plan sound. In summary
we highlight the following issues
1. Recommended changes to policy wording
We are pleased to see the site assessments and sustainability appraisal for the
allocations. Although these are not full heritage impact assessments, these
assessments do make some helpful recommendations for the sites.
However, these recommendations are not always reflected in the policy.
As currently drafted, there is sometimes either a lack of criteria or insufficient
detail within the site-specific policies for the conservation and enhancement of
the historic environment. The NPPF (para 16d) makes it clear that Plans should
contain policies that are clearly written and unambiguous, so it is evident how a
decision maker should react development proposals. Further advice on the content of
policies is given in the PPG at Paragraph: 002 Reference ID: 61-002-20190315
Revision date: 15 03 2019. It states that, ‘Where sites are proposed for allocation,
sufficient detail should be given to provide clarity to developers, local communities
and other interested parties about the nature and scale of development’.
We have therefore suggested a number of relatively minor changes to the policies to
incorporate these recommendations and address some of our concerns.
2. Heritage Impact Assessment of Bawburgh Site
The Bawburgh Site is perhaps most sensitive in heritage terms. There are several
designated heritage assets nearby including the Conservation Area, listed buildings
and scheduled monuments. Indeed, the Site Assessment states that a Heritage
Impact Assessment (HIA) may be required. We concur with this.
Paragraph 31 and 192 of the NPPF requires a proportionate evidence base for Plans
and we consider that an HIA for this site would help to ensure a robust evidence
base for the Local Plan.
Therefore, we recommend that a proportionate Heritage Impact Assessment is
undertaken now to inform the suitability of the site per se, assess the impact, identify
any mitigation and enhancement required and inform any changes to policy wording.
We would remind you that paragraph 32 of the NPPF makes it clear that significant
adverse impacts should be avoided wherever possible and alternative options
pursued. Only where these impacts are unavoidable should suitable mitigation
measures be proposed. Further detail is given in the attached table.
Where a potential impact is identified, wording should be included in the policy and
supporting text to this effect. We suggest the inclusion of additional bullet point in the
site allocation. Ideally, the bullet point should mention the specific asset(s), the policy
requirement (see wording in appendix) and any potential mitigation required.
Closing comments
We have suggested a series of other changes to the Plan. Many of these changes
suggested do not go to the heart of the Plan’s soundness, but instead are intended to
improve upon it. We believe that these comments can be addressed by changes to
wording in the plan.
In preparation of the local plan, we encourage you to draw on the knowledge of local
conservation officers, the county archaeologist and local heritage groups.
Historic England, Brooklands, 24 Brooklands Avenue, Cambridge CB2 8BU
Telephone 01223 58 2749 HistoricEngland.org.uk
Please note that Historic England operates an access to information policy.
Correspondence or information which you send us may therefore become publicly available.
Please note that absence of a comment on a policy, allocation or document in this
letter does not mean that Historic England is content that the policy, allocation or
document is devoid of historic environment issues. We should like to stress that this
response is based on the information provided by the Council in its consultation. To
avoid any doubt, this does not affect our obligation to provide further advice and,
potentially, object to specific proposals, which may subsequently arise as a result of
this plan, where we consider that these would have an adverse effect upon the
historic environment.


GNLP5004
Land off Buxton Road, Eastgate, Cawston
The policy states that an archaeological assessment will be required prior to development which is broadly welcomed. The SA recommends that the policy should make it clear whether these should be desk based of field studies. Moreover, in our view, some assessment is needed to inform any planning application. We therefore advise that the criterion should be amended to read, ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’
The SA also recommends that the landscaping should be species appropriate to the local area.
Amend policy re archaeological assessment to read ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’ And make clear if desk based or field based appropriate.
Amend policy to state that ‘landscaping should be species appropriate to the local area.’

GNLP5005
Strayground Lane, Wymondham Recycling Centre
No comments

GNLP5009 Hockering Lane, Bawburgh

Whilst there are no designated heritage assets within the site, the Bawburgh Conservation Area lies to the west of the site but is separated by a block of development. There are listed buildings and scheduled monuments to the north west of the site across the valley. The development has the potential to impact the significance of these heritage assets via a change in their settings.
The Site assessment suggests the preparation of a Heritage Impact Assessment. The Sustainability Appraisal identifies negative impact.
Given this is one of the more sensitive sites in heritage terms, an HIA should be prepared now to inform the suitability of the site per se and the policy wording.
The policy states that an archaeological assessment will be required prior to development. As with the Cawston site it would helpful for the policy to state if the assessment should be desk based or field based. Moreover, in our view, some assessment is needed to inform any planning application. We therefore advise that the criterion should be amended to read, ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’
The SA recommends that the policy should protect or where possible enhance the trees and hedgerow surrounding the site, which would be likely to help conserve the landscape character and historic settings of nearby heritage assets in Bawburgh by ensuring the site is appropriately screened. This should be included in the policy.
We recommend an HIA is prepared now prior to inform the suitability of the site and policy wording.
Amend policy re archaeological assessment to read ‘Planning applications should be supported by archaeological assessment including the results of field evaluation where appropriate.’ And make clear if desk based or field based appropriate.
Add criterion to read ‘Protect and enhance the trees and hedgerows surrounding the site to conserve the landscape character and historic settings of nearby heritage assets in Bawburgh by ensuring the site is appropriately screened’.

GNLP5014
A47 North Burlingham Junction
We welcome bullet point 3 in relation to landscaping to protect views of non-designated heritage assets nearby.

GNLP5019 Woodland Stable, Shortthorn Road, Stratton Strawless
No comments

GNLP5020 Romany Meadow, The Turnpike, Carleton Rode
Whilst there are no designated heritage assets within the site, there are several grade II listed buildings nearby including The Ashes to the east and a cluster of grade II properties to the northwest. However, the site is quite well contained and intervening landscaping should limit the impact on the historic environment.
We welcome bullet point 4 in relation to landscaping to protect views of nearby listed buildings.

GNLP5021 The Old Produce Shop, Holt Road, Horsford
No comments

GNLP5022 The Oaks, Foulsham
This is an extension of an existing site. Whilst there are no designated heritage assets within the site, the grade II* church of St Andrew lies to the south east of the site. There are three grade II listed buildings close by including Manor Farm House to the west, Old Hall to the East and Old Hall Farmhouse to the north east of the site. However, the site is well screened and there is intervening off- site vegetation. Therefore, we consider any impact on designated heritage assets would be minimal.
We welcome bullet point 4 in relation to landscaping to protect views of nearby listed buildings.

GNLP5023 Strayground Lane, Wymondham
The SA states that the policy could be further improved by detailed requirements to consider landscaping measures to reduce potential for adverse effects on the surrounding landscape character
Add policy criterion to read
‘Landscaping measures to reduce potential for adverse effects on the surrounding landscape character’

GNLP5024 Upgate Street, Carleton Rode
Whilst there are no designated heritage assets within the site, there are two grade II listed buildings to the north of the site and the New Buckenham Conservation Area to the west of the site. The site assessment states that Bunns Bank Linear Earthwork, which elsewhere in its course is scheduled, is adjacent to the site and should be taken into consideration. This requirement should be included in the policy wording of the Plan. We suggest an additional bullet point to the policy criteria.
However, overall the site is well screened and there is intervening off- site vegetation. Therefore, we consider any impact on designated heritage would be minimal.
Amend policy wording to add bullet point to read:
‘Protect the adjacent Bunns Bank Linear Earthwork.‘

Reasonable Alternative Site Policy GNLP5013 Ketteringham Depot land west of Station Lane, Ketteringham
Whilst there are no designated heritage assets within the site boundary, there are two round barrows (scheduled monuments) to the south of the site and several grade II listed buildings nearby. However, these are all over 500 metres from the site. Given the distance and intervening vegetation, we consider there would be little impact on designated heritage.

Object

Greater Norwich Local Plan Gypsy and Traveller Sites Focused Consultation

Representation ID: 25184

Received: 17/03/2023

Respondent: Charles and Judy Levien

Number of people: 2

Representation Summary:

We wish to respond to the Greater Norwich Local Plan for Gypsy and Traveller Sites. ( GNLP 5022)
We have lived here for 33 years and have always valued the quiet rural nature of the countryside around here.
We are very concerned about the expansion of the site known as The Oaks in Reepham Road.
Following a Planning Appeal on 27th February 2014, Mr Morgan was given permission for 2 static caravans, 2 touring caravans and 4 personal vehicles at the rear of the field which opens onto Reepham Road. After 9 years, this site has grown to accommodate at least 5 families (judging from the wheelie bins and further static homes that have been built. This has all been done without planning permission, which is very annoying for the local community who abide by planning laws. In addition a new opening onto Reepham Road has been made to access the field they have bought at the rear. ( we believe without permission)

We attended the Planning Appeal in 2014 for The Oaks. (APP/K2610/A/13/2203023)
There are a number of items we wish to raise and it may be helpful to do that in the order of those included in the report.

No. 10 in the report refers to the need to safeguard the the scenic quality of the area (ENV 8). No regard has been given to this condition in the last nine years.

No 11. Refers to the number of pitches. In the Local Plan it was estimated that no more than 35 pitches would be needed in Broadland from 2012 to 2026. This has now been nearly doubled to 62.

No 24. Refers to the ‘generous set back’ of the traveller site so that it is not seen from Reepham Road. This is no longer the case. The site at present is totally out of keeping with the area and covers the whole of the front field.

No 25 refers to the cladding of the buildings being visually recessive. This is clearly not the case here. Also that the hedges be indigenous, which being cupressus leylandii and bay laurel they are not.

No 26 refers to ENV8 and GS3 being compromised. The implication of the proposal would mean further compromise of the character and visual qualities of the area.

No 28 states that the site should not dominate the nearest settled community. We would argue that the present development at the Oaks already does that.

No 29 refers to sewage. As it stands there is very little checking of conditions met. How will the sewage system be maintained and nutrient neutrality ensured?

No 34 refers to the reliance on cars that undermine the LP policy GS3 JCS policy 1. The site is two kilometers from Foulsham (so called the ‘service village’). There are no buses for 3-4 miles. The appeal conditions are that no more than four cars should be allowed. If the site increases to 10 pitches does that mean that there are now 20 cars allowed?

No 40. Refers to the fact that it is accepted that the development will harm the countryside ( and that was for just two families). In the Appeal it was recognised this would conflict with the development plan. Does this have any meaning now?

The Appendix in the Appeal Report states that no more than 4 caravans should be allowed and only two of them static.

These conditions have been disregarded over the last few years. What chance is there that any future development would remain within planning law?
It is on these grounds that we strongly object to the expansion of accommodation on this site. And furthermore, why is the Council not being seen to monitor and enforce conditions?

Full text:

We wish to respond to the Greater Norwich Local Plan for Gypsy and Traveller Sites. ( GNLP 5022)
We have lived here for 33 years and have always valued the quiet rural nature of the countryside around here.
We are very concerned about the expansion of the site known as The Oaks in Reepham Road.
Following a Planning Appeal on 27th February 2014, Mr Morgan was given permission for 2 static caravans, 2 touring caravans and 4 personal vehicles at the rear of the field which opens onto Reepham Road. After 9 years, this site has grown to accommodate at least 5 families (judging from the wheelie bins and further static homes that have been built. This has all been done without planning permission, which is very annoying for the local community who abide by planning laws. In addition a new opening onto Reepham Road has been made to access the field they have bought at the rear. ( we believe without permission)

We attended the Planning Appeal in 2014 for The Oaks. (APP/K2610/A/13/2203023)
There are a number of items we wish to raise and it may be helpful to do that in the order of those included in the report.

No. 10 in the report refers to the need to safeguard the the scenic quality of the area (ENV 8). No regard has been given to this condition in the last nine years.

No 11. Refers to the number of pitches. In the Local Plan it was estimated that no more than 35 pitches would be needed in Broadland from 2012 to 2026. This has now been nearly doubled to 62.

No 24. Refers to the ‘generous set back’ of the traveller site so that it is not seen from Reepham Road. This is no longer the case. The site at present is totally out of keeping with the area and covers the whole of the front field.

No 25 refers to the cladding of the buildings being visually recessive. This is clearly not the case here. Also that the hedges be indigenous, which being cupressus leylandii and bay laurel they are not.

No 26 refers to ENV8 and GS3 being compromised. The implication of the proposal would mean further compromise of the character and visual qualities of the area.

No 28 states that the site should not dominate the nearest settled community. We would argue that the present development at the Oaks already does that.

No 29 refers to sewage. As it stands there is very little checking of conditions met. How will the sewage system be maintained and nutrient neutrality ensured?

No 34 refers to the reliance on cars that undermine the LP policy GS3 JCS policy 1. The site is two kilometers from Foulsham (so called the ‘service village’). There are no buses for 3-4 miles. The appeal conditions are that no more than four cars should be allowed. If the site increases to 10 pitches does that mean that there are now 20 cars allowed?

No 40. Refers to the fact that it is accepted that the development will harm the countryside ( and that was for just two families). In the Appeal it was recognised this would conflict with the development plan. Does this have any meaning now?

The Appendix in the Appeal Report states that no more than 4 caravans should be allowed and only two of them static.

These conditions have been disregarded over the last few years. What chance is there that any future development would remain within planning law?
It is on these grounds that we strongly object to the expansion of accommodation on this site. And furthermore, why is the Council not being seen to monitor and enforce conditions?

Comment

Greater Norwich Local Plan Gypsy and Traveller Sites Focused Consultation

Representation ID: 25238

Received: 08/03/2023

Respondent: Avison Young

Representation Summary:

Representations on behalf of National Gas Transmission
National Gas Transmission has appointed Avison Young to review and respond to local planning authority Development Plan Document consultations on its behalf. We are instructed by our client to submit the following representation with regard to the current consultation on the above document.
About National Gas Transmission
National Gas Transmission owns and operates the high-pressure gas transmission system across the UK. In the UK, gas leaves the transmission system and enters the UK’s four gas distribution networks where pressure is reduced for public use.
Proposed sites crossed by or in close proximity to National Gas Transmission Assets
Following a review of the above document we have identified that one or more proposed development sites have been identified as being crossed or in close proximity to National Gas Transmission assets. Details of the sites affecting National Gas Transmission assets are provided below.

Development Plan Document Site Reference
Site GNLP5022 – The Oaks, Foulsham

Asset Description
Gas Transmission Pipeline, route: BACTON TO KINGS LYNN

A plan showing details of the site locations and details of National Gas Transmission’s assets is attached to this letter. Please note that the plan is illustrative only.
National Gas Transmission also provides information in relation to its assets at the website below.
• https://www.nationalgas.com/land-and-assets/network-route-maps
Please see attached information outlining guidance on development close to National Gas Transmission infrastructure.

Further Advice
National Gas Transmission is happy to provide advice and guidance to the Council concerning their networks.
Please see attached information outlining further guidance on development close to National Gas Transmission assets. If we can be of any assistance to you in providing informal comments in confidence during your policy development, please do not hesitate to contact us.
To help ensure the continued safe operation of existing sites and equipment and to facilitate future infrastructure investment, National Gas Transmission wishes to be involved in the preparation, alteration and review of plans and strategies which may affect their assets. Please remember to consult National Gas Transmission on any Development Plan Document (DPD) or site-specific proposals that could affect National Gas Transmission’s assets.

Full text:

Representations on behalf of National Gas Transmission
National Gas Transmission has appointed Avison Young to review and respond to local planning authority Development Plan Document consultations on its behalf. We are instructed by our client to submit the following representation with regard to the current consultation on the above document.
About National Gas Transmission
National Gas Transmission owns and operates the high-pressure gas transmission system across the UK. In the UK, gas leaves the transmission system and enters the UK’s four gas distribution networks where pressure is reduced for public use.
Proposed sites crossed by or in close proximity to National Gas Transmission Assets
Following a review of the above document we have identified that one or more proposed development sites have been identified as being crossed or in close proximity to National Gas Transmission assets. Details of the sites affecting National Gas Transmission assets are provided below.

Development Plan Document Site Reference
Site GNLP5022 – The Oaks, Foulsham

Asset Description
Gas Transmission Pipeline, route: BACTON TO KINGS LYNN

A plan showing details of the site locations and details of National Gas Transmission’s assets is attached to this letter. Please note that the plan is illustrative only.
National Gas Transmission also provides information in relation to its assets at the website below.
• https://www.nationalgas.com/land-and-assets/network-route-maps
Please see attached information outlining guidance on development close to National Gas Transmission infrastructure.

Further Advice
National Gas Transmission is happy to provide advice and guidance to the Council concerning their networks.
Please see attached information outlining further guidance on development close to National Gas Transmission assets. If we can be of any assistance to you in providing informal comments in confidence during your policy development, please do not hesitate to contact us.
To help ensure the continued safe operation of existing sites and equipment and to facilitate future infrastructure investment, National Gas Transmission wishes to be involved in the preparation, alteration and review of plans and strategies which may affect their assets. Please remember to consult National Gas Transmission on any Development Plan Document (DPD) or site-specific proposals that could affect National Gas Transmission’s assets.

Attachments: